Accountability

The Frame Game

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There is power in “framing” political discourse and policy development: Those who control the frame, control the content, the context, and more. In short, “He Who Sets the Frame Controls the Game”.

What just happened in the NFMA Rule Development game? The comment period closed yesterday. The frame was set by rehashing experience in planning, then constructing five “Substantive Principles for a New Rule” and three “Process Principles” (each with a battery of related questions). How many people, do you suppose, chose to respond outside that frame? How powerful was the frame?

In my formal comment I said that I wish the Forest Service had simply established a blog, and begun with a simple question, like: “Given the noble ideas embedded in RPA/NFMA (Wikipedia link) and other principal laws related to the Forest Service, how might the planning/management process of the USDA Forest Service be improved?” Then I said that I hoped someday the FS would indeed engage the public in meaningful inquiry as to its operations and the management of the national forests. Not yet, though. I added:

Unfortunately but not unexpectedly given the RPA context, these regulations have been dubbed a “planning rule.” If one looks at RPA/NFMA through the lens of adaptive management, the process outlined in Section 6 looks much different than if one views it through the lens of comprehensive rational planning. Unfortunately, all previous “NFMA rules” (and associated forest plans) have been developed under the “comprehensive rational planning” frame.

We must remember that the Clinton era Committee of Scientists recommended that a forest plan be viewed through an adaptive management lens — viewed, figuratively, as a loose-leaf compendium of all assessments, decisions, monitoring and evaluation efforts, etc. that affect an administrative unit of the national forest system. …

If so-called “planning rule” development is viewed, once again, as yet-another comprehensive, rational planning exercise, the agency will be mired again in analysis paralysis and process gridlock. If viewed as a mandate for adaptive management with a heavy dose of collaborative engagement on the part of other agencies, other governments, and citizens, then a whole new world of opportunity and challenge opens up to the Forest Service.

Please do not fall into the ‘planning trap’ again.

Now we wait for “next steps” and for a “Draft Rule.” And we hope that we — all of us, both the Forest Service and the public — won’t be trapped in an inappropriate “frame.” It is not that I believe that the Forest Service deliberately manipulated the “frame” in this case. Just the opposite. I believe the Forest Service fell into common decision traps: “frame blindness”, “lack of frame control”, “plunging in”, others?

Related:
Adaptive Forest Management blog
Earth to FS Planning: Get a Blog!
The Forest Service as a ‘Learning Challenged’ Organization, (1999)

Earth to FS Planning: Get a Blog!

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Yes I know that the FS thinks it has a Planning Rule blog. But it doesn’t. Not a real blog anyway. All it has, so far, is a poor excuse for a comment aggregator. The other day I decided to leave a comment on Peter Williams’ recent post on the “official blog”. Guess what? The so-called blog won’t accept comments that include paragraph breaks. No HTML is allowed. And, best I can tell, even simple “http” references are not converted to active links. So I decided that until and unless the FS is willing to at least fix the paragraph breaks problem—or tell folks how to use the blog so that it will include “breaks”—I will just use real blogs outside the “official” smokescreen. Here is the comment I intended to post as a response to Peter, slightly edited:

Here is my “take” on Peter Williams’ final two questions, restated a wee bit:

How might the planning rule provide for an all lands approach and address the contribution of NFS lands to local communities?

  • How can the new planning rule, by itself or as a road map for developing forest plans, reflect the interdependency of social, economic, and ecological systems in a way that supports sustainable management of national forests and grasslands?
  • How can it help provide or ensure opportunities for goods and services to support vibrant rural, regional, and national economies?

My guess is that any planning rule that is developed in the long tradition of “rules” dating back to 1979 will not be helpful in achieving the goals embedded in the questions. Why? Because the focus of each “rule” has always been on developing a “Forest Plan” as if there were wide discretion in that process and “as if” the forest administrative unit made sense as an overall “catchall” for decision-making. Neither is the case.

One problem is that there can not be wide discretion in forest-level decision-making if only because the ecosystems embedded in each administrative unit of the national forest system are themselves part of broader ecosystem wholes, e.g. larger watersheds, larger “basin and range” systems, both, and more. This means that what works for sustainability (instead of against) re: “forest subsystem contributions” to ecosystems must be informed by the needs of broader wholes. So too with social systems. An “all lands approach” must be scaled, hierarchically, to guide development of plans at subscales. Maybe a NFMA “rule” can address such, but we haven’t seen one yet. Only with such an adaptive management assessment information system could forest-level decision-making begin to make any sense. And the ecosystems/social systems scale problem is but one of many problems that impede wide discretion in decision-making. Another is what I call the “wicked problem” problem.

The Forest Service has never (to my knowledge) addressed “wicked problems” (Wikipedia link: http://en.wikipedia.org/wiki/Wicked_problem. Such problems were first introduced to the Forest Service in 1986 by Allen and Gould (Journal of Forestry) and to the world by Rittel and Webber in 1973 (Policy Sciences). Anyone who has studied forest management problems knows that they are indeed politically wicked and cry out for approaches much different from the “comprehensive rational planning” approach that the Forest Service always gravitates toward. Even when dressed up with terms like “adaptive” or “adaptive management” the reality of the approaches used always have rational-planning at their core.

One thing is certain when dealing with wicked problems: You can only hope to accomplish anything when you are able to define the scope the problem (time, space, issues, etc.) into “decision containers” that people (stakeholders, administrators, etc) can get their minds around. It seems that traditional “forest plan” containers are hopelessly over-filled when land management zoning, land management goals and objectives, program goals and objectives, and related “standards and guidelines” are all in play — and “in play” in a spatial container that isn’t really relevant to many of the objectives at hand. I have long felt that rational planning approaches simply can’t work. Here is how I put it in my Epistle to the Clinton-era Committee of Scientists (link: http://www.fs.fed.us/eco/eco-watch/cos_greenplans.html) , written when I was an employee of the Forest Service:

… [W]e have failed to learn the lesson that there is a difference between complex problems and wicked problems (see: G.M. Allen’ and E.M. Gould. 1986. “Complexity, wickedness, and public forests.” J.For 84(4):20-23, also Henry Mintzberg. 1994. The Rise and Fall of Strategic Planning). According to Allen and Gould, politically wicked problems can not be solved by any multi-step planning process designed to “collect more data, build bigger models, and crunch more numbers … [expecting that] surely the right answer would be forthcoming.” Allen and Gould suggest that the Forest Service’s general operating norm for planning–more data, fancier analysis, more computing power, more scientists–reflects a “naive hope that science can eliminate politics.” This problem went unresolved–is still unresolved–because [Forest Service] ‘professional arrogance’ wouldn’t allow [the agency] to admit that national forest management and planning is ‘political’.

Why not try adaptive management, better still Adaptive Co-Management (Resilience Alliance Link: http://www.resalliance.org/2448.php) when thinking in terms of an “all lands approach”. Note here that the adaptive management I’m talking about is multiple-scale oriented, addresses wicked problems, and involves double loop learning (More here: http://en.wikipedia.org/wiki/Organizational_learning). Maybe such adaptive co-management can be and will be fit into the NFMA “rule” rewrite. But I doubt it. As I mentioned in an earlier post, I hope I am proven wrong.

Final thought: If adaptive co-management is to work, decision-makers will have to constantly check and “be checked” to make sure that decisions (cumulatively) aren’t afflicted with policy “decision traps.” E.g. a set of decisions might be afflicted with “policy drift” — a “tyranny of small decisions” that eventually runs counter to policy aims due to the cumulative effects of sequential or segmented decisions.

Should Congress Let the Forest Service Off for Good Behavior?

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From Andy Stahl

Some have suggested that Congress amend NFMA, establish a public land law review commission, or otherwise lessen the binds of environmental law. They say that the Forest Service has been reformed, that logging is no longer a problem, or that other problems (e.g., climate, insects, private land use) not addressed by NFMA are now paramount.

Wall Street bankers made the same plea in 1999 when they persuaded Congress to repeal the Depression-era regulations that separated commercial and investment banking. Lo and behold, it didn’t take long for the banks to remind us that where there’s money to be made, it will be, and damn the consequences.

Money still grows on Forest Service trees, ripe for the agency’s plucking. The well-intentioned laws (Knutson-Vandenberg, Brush Disposal, Salvage Sale Fund) that allow the Forest Service to supplement its appropriated budget with timber sale dollars remain on the books. In 2000, President Clinton’s USDA proposed to eliminate the off-budget timber funds by re-directing all timber sale receipts to the U.S. Treasury. Guess who opposed the move? Mark Rey, who in 2005, thanks to a midnight appropriations bill rider, expanded K-V spending authority to include paying for green timber sale planning and administration.

Randal O’Toole’s diagnosis, if not his therapy, remains as sound today as when he published Reforming the Forest Service in 1988. And the odds of eliminating these perverse legislative incentives remain as unlikely as the reimposition of any limits on bankers’ greed.